Giovanna Sparagna is a member of Sutherland’s Tax Practice Group advising multinational corporations on international tax planning and controversy matters involving cross-border financing, royalty structures, mergers and acquisitions, contract manufacturing structures, cross-border service and supply agreements, and repatriation planning.

As a consequence of her large multinational practice, Ms. Sparagna handles substantial transfer pricing matters for Fortune 50 companies and foreign-owned clients working closely with economic experts in tax planning (e.g., establishing cost sharing and related party licensing arrangements); assessing multi-jurisdictional transfer pricing exposure; complying with FIN 48 and return documentation requirements; and developing audit, litigation, advance pricing agreement and competent authority strategies.

Ms. Sparagna has also handled controversy matters involving government challenges to:

• cross-border financing transactions involving arbitrage elements such as deferred share agreements and “repo” transactions;
• foreign tax credits under non-compulsory and economic substance theories;
• offshore intangible structures;
• treaty exemptions on complex, multi-party financing transactions; and
• validity of international restructuring.

Before joining the firm, Ms. Sparagna served in the Office of the Chief Counsel (Internal Revenue Service) rendering rulings and legal advice on domestic and international mergers, acquisitions, and dispositions. Additionally, she is a former adjunct professor of law at Georgetown University Law Center.